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A government website accessibility checklist should do more than run a scanner. It must define the legal and technical target, cover every public-facing service and supplier component, combine automated and manual testing, assign and retest defects, and publish a current accessibility statement. For UK public-sector websites and mobile apps, current GOV.UK guidance identifies WCAG 2.2 Level AA as the target. The same governance model can be adapted to other jurisdictions by adding the applicable national rules.
Use the checklist below as a service-delivery control: establish ownership and scope, set acceptance criteria before build, test representative journeys with more than one method, document exceptions and alternatives, and keep evidence current after launch.
1. Establish ownership, scope and legal context
Accessibility is a public body’s responsibility even when an external supplier designs, hosts or maintains the service. Name an accountable service owner and an accessibility lead before procurement or development begins. Give both people authority to stop a release, require remediation and approve a documented exception.
Build a complete service inventory
List every asset a member of the public may need, not just the main domain:
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- Public websites, campaign microsites and subdomains.
- Native mobile applications and mobile web views.
- Authenticated journeys such as account creation, identity checks and case tracking.
- Forms, search, payments, bookings, notifications and other transactions.
- HTML pages, PDFs, spreadsheets, videos, maps and downloadable documents.
- Third-party widgets, embedded services, chat, analytics consent tools and payment components.
- Intranets or extranets used by residents, contractors or partner organisations.
- Legacy services that remain available through redirects or bookmarked URLs.
For each item, record the jurisdiction, responsible owner, technology stack, supplier, release cadence, accessibility standard, known exemptions and next review date. Include the journeys that require a login and the content supplied by another organisation; an outsourced component does not transfer legal accountability away from the public body.
Record the governing framework
For UK public-sector work, note that the Public Sector Bodies (Websites and Mobile Applications) Accessibility Regulations 2018 came into force on 23 September 2018. GOV.UK guidance from the Government Digital Service, current on 27 September 2024, identifies WCAG 2.2 Level AA for public-sector websites and apps. Record the exact standard and version in the project brief rather than writing only “accessible”. If the service is procured as broader information and communications technology, map requirements to EN 301 549 and the applicable national framework.
US federal teams should add Section 508 procurement requirements. The standard selected for a project must match its jurisdiction, product type and contract; do not assume that a website target automatically covers every document, software component or hardware item in a wider ICT purchase.
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A contract or delivery plan needs observable pass/fail evidence. State which version of WCAG applies, which browsers and operating systems are supported, and which user journeys must work without a mouse, touch screen or particular device.
| Area | Acceptance evidence to require |
|---|---|
| Keyboard and focus | Every control and complete journey works with a keyboard; focus is visible, logical and not trapped; dialogs return focus appropriately. |
| Structure and navigation | Headings, landmarks, page titles, link purpose and reading order are meaningful and programmatically exposed. |
| Visual presentation | Text remains usable at the required zoom; content reflows on a narrow viewport without loss of information or two-dimensional scrolling where WCAG requires reflow; contrast and non-text contrast meet the selected criteria. |
| Forms and errors | Labels, instructions, required fields, validation messages and error recovery are available to assistive technology and usable by keyboard. |
| Dynamic content | Status messages, validation results, loading states and updates are announced or otherwise discoverable without forcing a user to search the page. |
| Media and documents | Captions, transcripts, audio description where required, accessible PDFs and equivalent HTML alternatives are supplied. |
| Devices and browsers | The supported browser/device matrix is tested, including small screens, orientation changes and touch targets relevant to the service. |
Define what evidence is delivered at acceptance: test URLs, browser and assistive-technology versions, screenshots or recordings where useful, defect identifiers, retest results and a signed statement of any accepted risk. A supplier’s generic conformance claim is not a substitute for evidence from the exact version and configuration being purchased.
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3. Choose a representative test sample
You do not need to inspect every page in the first review. GOV.UK monitoring guidance recommends a representative sample that exposes issues across templates and journeys. Select pages and states deliberately, then expand the sample when a defect pattern appears.
Include these page and journey types
- Home page, global navigation, footer, contact and accessibility statement.
- Each page template and major content type, including long-form guidance, tables and media.
- Search, filtering, pagination and an empty-results state.
- Registration, sign-in, password recovery, identity verification and sign-out.
- High-risk transactions such as applications, payments, bookings and appeals.
- Forms with valid input, missing input, invalid formats, duplicate submissions and session timeout.
- Success, warning, error, maintenance and authentication-expiry messages.
- Documents and embedded or third-party content that users must reach to complete the task.
- Responsive layouts at a small phone width, tablet width and desktop width, plus zoomed text.
Write down why each item represents the service. A sample that contains only the home page and a content article cannot demonstrate that a payment or benefits application is accessible.
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Run an automated scanner such as Axe as a first pass, not as an audit verdict. Automated tools efficiently detect some missing labels, duplicate IDs, contrast problems and structural errors, but GOV.UK guidance warns that they do not find every accessibility issue.
Manual keyboard and focus checks
- Disconnect or ignore the mouse and complete each sampled journey with the keyboard.
- Use Tab, Shift+Tab, Enter, Space and arrow keys where appropriate; verify that custom controls expose expected keyboard behavior.
- Check that focus order follows the task, focus is always visible, and no modal, carousel or menu traps the user.
- Confirm that a “skip to content” mechanism or equivalent makes repeated navigation manageable.
Zoom, reflow and small-device checks
- Increase browser zoom and text size to the levels required by the selected WCAG criteria.
- Inspect a narrow viewport and portrait orientation. Look for clipped controls, overlapping text, hidden instructions and horizontal scrolling that prevents completion.
- Test touch and pointer interactions on a small device, including the spacing and size of controls used in essential tasks.
Semantics, forms and updates
- Navigate by headings and landmarks with a screen reader; confirm names, roles, states and values for custom widgets.
- Submit forms with missing, malformed and conflicting values. Verify that errors identify the field, explain the correction and remain available after focus moves.
- Trigger dynamic updates such as search suggestions, upload progress, alerts and session warnings. Confirm that a non-visual user receives the same important information.
- Check captions, transcripts, audio controls, document structure, link purpose and meaningful alternative text.
Include people and assistive technologies where possible
For a high-risk or complex service, involve people with a range of disabilities or representative accessibility personas. Record the assistive technology, browser, operating system and configuration used; the same page can behave differently across combinations. Commission a detailed independent audit when the service is legally significant, technically complex or repeatedly failing internal checks, then retest after remediation.
5. Log, prioritise and retest defects
One defect record should allow another tester to reproduce the problem and understand its public impact. Capture:
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- URL, screen, component or document and the affected journey.
- Applicable WCAG success criterion and, where relevant, EN 301 549 or Section 508 requirement.
- Plain-language description of what a user cannot do and who is affected.
- Reproduction steps, expected result, actual result, browser, device and assistive technology.
- Severity, owner, target date, temporary workaround and permanent fix.
- Retest date, evidence and final status.
Prioritise by service consequence
Fix blockers in core public transactions first: authentication, payments, applications, forms, document submission and information needed to exercise rights or obtain essential services. A cosmetic issue on an informational page may be lower priority than a keyboard trap in a benefits application, even if both map to a WCAG criterion. Set due dates that match release risk and publish escalation rules for overdue defects.
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Handle exceptions transparently
If a requirement cannot be met, document the specific content or function, the reason, evidence considered, affected users, mitigation and an alternative access route. Where the governing framework allows an exemption or disproportionate-burden decision, record the decision-maker, date and review trigger. An exception is not a reason to omit testing or to mark the whole service compliant.
6. Publish and maintain the accessibility statement
Publish an HTML accessibility statement prominently, normally from the footer of every page. It should be understandable without specialist knowledge and accurate for the service version a person is using.
Required content
- The service’s compliance status: fully, partially or not compliant.
- The standard and version used for evaluation.
- Known non-compliant areas, the reason for each, and planned remediation dates.
- Any content or functionality excluded under a lawful exemption or disproportionate-burden decision.
- Instructions for obtaining inaccessible content in an alternative format or through another channel.
- A way to report an accessibility problem, including a monitored contact method.
- The escalation or complaints route when the response does not resolve the issue.
- The evaluation method, scope, testing date and relevant environment.
- The statement’s publication or revision date and the next review trigger.
Keep a version history internally so the public statement can be traced to test evidence. GOV.UK says statements should be reviewed and updated regularly, including at least once a year, and after major changes. Update it sooner when a new template, transaction, supplier component or legal requirement changes the accessibility risk.
7. Put accessibility into an RFQ and supplier contract
Accessibility must appear in the request for quotation, evaluation, statement of work, acceptance test and renewal decision. Copying a standard name into a contract without defining evidence leaves the public body exposed.
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| Procurement stage | Questions and controls |
|---|---|
| Market research | Can the supplier demonstrate the required WCAG, EN 301 549 or Section 508 capabilities on the actual product and supported configuration? What testing methods, assistive technologies and remediation process are used? |
| RFQ and evaluation | Make accessibility a scored criterion. Require a completed conformance report, known limitations, sample test evidence, supported browser/device matrix and named accessibility contact. |
| Statement of work | Specify user journeys, documents, third-party integrations, WCAG version, defect severity definitions, evidence format and the public body’s right to test independently. |
| Acceptance | Set pass/fail gates for keyboard, focus, zoom, reflow, forms, media, PDFs, error handling and dynamic updates. Do not accept a generic vendor declaration in place of delivered-service testing. |
| Operations and change control | Require periodic reviews, cooperation with independent testing, notice of component changes, remediation time limits, regression testing and accessibility evidence for releases. |
| Renewal or exit | Use unresolved high-impact defects, missed review obligations and stale conformance evidence in renewal decisions. Require accessible data export and transition support if the contract ends. |
Ask for evidence tied to the exact version and configuration being bought. Verify it with your representative sample and with users where feasible. Supplier responsibility for fixing a component does not remove the public body’s responsibility to publish an accurate statement or provide an alternative route while a defect remains.
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Make accessibility part of normal delivery rather than a one-time launch exercise.
- Discover: map users, legal obligations, assisted channels, content and high-risk transactions.
- Design: include accessible interaction patterns, content rules, document requirements and testable acceptance criteria in prototypes and designs.
- Build: run automated checks in development and code review; prevent new keyboard, focus, semantic and contrast regressions.
- Pre-release: run the representative automated and manual suite, resolve blockers and obtain evidence for any accepted exception.
- Launch: publish or update the statement, reporting route and alternative access instructions.
- Operate: monitor complaints, analytics signals, supplier releases and content changes; retest after major changes.
- Review: perform at least an annual statement review and commission deeper independent testing for high-risk services.
Keep a single register linking requirements, test cases, defects, decisions, statements and release versions. This makes it possible to answer what was tested, with which technology, when a defect was fixed and whether the fix survived a later change.
9. Common checklist failures and how to correct them
“The scanner found no errors, so we are compliant.”
Automated coverage is partial. Add keyboard, focus, zoom, reflow, small-device, form, dynamic-content and assistive-technology checks, then test realistic journeys.
“We tested the home page.”
A single page cannot represent authentication, payment, document upload, error states or third-party components. Select samples by template, content type and user task, and expand them when patterns emerge.
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“The supplier said its product is accessible.”
Request version-specific evidence and test the delivered configuration. Put remediation, independent testing, change notification and acceptance rights into the contract.
“We will write the statement after launch.”
The statement is a public control, not marketing copy. Prepare its owner, reporting route, evaluation method and known limitations before release so users have an alternative when a problem is discovered.
“An exception means we can stop.”
Document the legal basis, impact, mitigation and alternative route, continue testing, and set a review date. An exception should narrow a decision, not hide an inaccessible journey.
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Before approving a public release, the service owner should be able to answer yes to each question:
- Is an accountable owner and accessibility lead named?
- Is the complete service and supplier inventory current?
- Is the applicable WCAG, EN 301 549, Section 508 or national target recorded with its version?
- Was a representative sample tested across templates, documents and critical journeys?
- Were automated results supplemented by manual keyboard, focus, zoom, reflow, small-device and form checks?
- Were assistive technologies, browsers and devices recorded?
- Are every blocker and high-impact defect assigned, dated and retested?
- Are exceptions, disproportionate-burden decisions and alternative routes documented?
- Does the accessibility statement contain status, known issues, dates, evaluation method, reporting and escalation details?
- Is there a funded review cadence after major changes and at least annually?
If any answer is no, record the risk and decision rather than implying conformance. The checklist is successful when a public user can complete an important task, report a barrier and obtain help while the organisation has evidence, ownership and a credible path to improvement.
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